Illinois Appeals Court: Landlord Proved Conversion of Its Billboard Structures, But Gets Only Nominal Damages

An Illinois appeals court found Link Media Midwest converted billboard structures on Michelmann's leased Quincy lot, but limited recovery to nominal damages because Michelmann never proved the structures' fair market value.

The Illinois Appellate Court's Fourth District ruled on October 26, 2026 in Michelmann Steel Construction Co. v. Link Media Midwest, LLC that Link Media, an outdoor-advertising company, converted billboard structures it removed from a Quincy, Illinois lot it leased from landlord Michelmann Steel Construction Company, reversing the trial court on that point. But because Michelmann never offered evidence of the structures' fair market value, as opposed to their replacement cost, the court held Michelmann is entitled only to nominal damages, and otherwise affirmed the Adams County circuit court's rulings, including a judgment in Michelmann's favor on unpaid rent under the decades-old lease.

Why it matters

The decision is a two-sided guide for commercial landlords and tenants dealing with structures left on leased land: a landlord can win on liability for a tenant's unauthorized removal of fixtures but still walk away with essentially nothing if it cannot put a dollar figure on what was taken, while a tenant or assignee that lets structures sit past a lease's removal window risks losing ownership of them outright. It also shows how holdover-tenancy elections can quietly extend a legacy lease's original terms, including rent escalators, for new assignees decades after the original parties signed.

Case timeline · 3 entries Latest: October 26, 2026 — Illinois Appellate Court, Fourth District affirms in part, reverses in part, and remands, finding conversion but limiting recovery to nominal damages

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